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ENVIRONMENTAL RESOURCES MANAGEMENT YARA DALLOL BV 7-1 7 STAKEHOLDER ENGAGEMENT This Chapter presents a summary of the stakeholder engagement activities as part of the ESIA process. It serves as a summary of a more detailed Stakeholder Engagement Programme described in the Stakeholder Engagement Plan (SEP - refer to Annex C in Part II of this ESIA) and presents the engagement approach, the stakeholders included in engagement activities, and the mechanisms through which they were and will continue to be engaged. The SEP also provides a means to document the stakeholder engagement process and includes meeting minutes, participant signatures, photographs etc. This Chapter has been structured to provide a summary of: The objectives of stakeholder engagement in the ESIA; The overall approach to stakeholder engagement; The engagement undertaken during in the screening phase; The engagement undertaken during the baseline phase The engagement undertaken during the draft ESIA consultation phase; The engagement undertaken during the final ESIA consultation phase; The next steps related to stakeholder engagement; and The feedback mechanism. 7.1 OBJECTIVES OF STAKEHOLDER ENGAGEMENT The objectives of engaging stakeholders during the ESIA process included: Ensuring Understanding – developing an open, inclusive and transparent process of culturally appropriate engagement and communication to ensure that stakeholders are well informed about the proposed Project. Involving Stakeholders in the Assessment – stakeholders were included in the scoping of issues, the assessment of impacts, the generation of mitigation and management measures and the finalisation of the ESIA report. Stakeholders play an important role in providing local knowledge and information for the baseline and to inform the impact assessment and mitigation. Building Relationships – through supporting open dialogue, engagement helped establish and maintain a productive relationship between the ESIA team and stakeholders. This supported an effective ESIA, but also strengthened the existing relationships between Yara Dallol BV and stakeholders. Engaging Vulnerable Peoples – an open and inclusive approach to consultation increases the opportunity for stakeholders to provide comment on the proposed Project and to voice their concerns. Some

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Page 1: 7 STAKEHOLDER ENGAGEMENT - ERM - Environmental … · ENVIRONMENTAL RESOURCES MANAGEMENT YARA DALLOL BV 7-1 7 STAKEHOLDER ENGAGEMENT This Chapter presents a summary of the stakeholder

ENVIRONMENTAL RESOURCES MANAGEMENT YARA DALLOL BV

7-1

7 STAKEHOLDER ENGAGEMENT

This Chapter presents a summary of the stakeholder engagement activities as

part of the ESIA process. It serves as a summary of a more detailed

Stakeholder Engagement Programme described in the Stakeholder

Engagement Plan (SEP - refer to Annex C in Part II of this ESIA) and presents

the engagement approach, the stakeholders included in engagement activities,

and the mechanisms through which they were and will continue to be

engaged. The SEP also provides a means to document the stakeholder

engagement process and includes meeting minutes, participant signatures,

photographs etc.

This Chapter has been structured to provide a summary of:

The objectives of stakeholder engagement in the ESIA;

The overall approach to stakeholder engagement;

The engagement undertaken during in the screening phase;

The engagement undertaken during the baseline phase

The engagement undertaken during the draft ESIA consultation phase;

The engagement undertaken during the final ESIA consultation phase;

The next steps related to stakeholder engagement; and

The feedback mechanism.

7.1 OBJECTIVES OF STAKEHOLDER ENGAGEMENT

The objectives of engaging stakeholders during the ESIA process included:

Ensuring Understanding – developing an open, inclusive and transparent

process of culturally appropriate engagement and communication to

ensure that stakeholders are well informed about the proposed Project.

Involving Stakeholders in the Assessment – stakeholders were included

in the scoping of issues, the assessment of impacts, the generation of

mitigation and management measures and the finalisation of the ESIA

report. Stakeholders play an important role in providing local knowledge

and information for the baseline and to inform the impact assessment and

mitigation.

Building Relationships – through supporting open dialogue, engagement

helped establish and maintain a productive relationship between the ESIA

team and stakeholders. This supported an effective ESIA, but also

strengthened the existing relationships between Yara Dallol BV and

stakeholders.

Engaging Vulnerable Peoples – an open and inclusive approach to

consultation increases the opportunity for stakeholders to provide

comment on the proposed Project and to voice their concerns. Some

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stakeholders need special attention in such a process due to their

vulnerability (for example, elderly, female headed households, children,

etc.). Special measures will be considered to ensure that the perspectives of

vulnerable stakeholders are heard and considered.

Managing Expectations – it is important to ensure that the proposed

Project does not create or allow unrealistic expectations to develop

amongst stakeholders with respect to proposed Project benefits. The

engagement process served as a mechanism for understanding and

managing stakeholder and community expectations by disseminating

accurate information in an accessible way.

Ensuring Compliance - the engagement process is designed to ensure

compliance with both local regulatory requirements and international best

practice.

One of the key outcomes of engagement should be free, prior and informed

consultation of stakeholders, where this can be understood to be:

Free – engagement free of external manipulation or coercion and

intimidation;

Prior – engagement undertaken in a timely way, for example the timely

disclosure of information early in the ESIA process; and

Informed – engagement enabled by relevant, understandable and

accessible information.

7.2 APPROACH TO STAKEHOLDER ENGAGEMENT

Stakeholder engagement for the ESIA was undertaken using a staged

approach in line with the various phases of the ESIA process. All engagement

has been developed according to Ethiopian legislative requirements and with

consideration of IFC Performance Standards.

Stakeholder engagement for an ESIA has five key phases, shown in Figure

7.1below.

Figure 7.1 ESIA Engagement Phases

The objectives of each engagement phase are presented below in Table 7.1.

Screening Scoping Baseline

Data Gathering

Draft ESIA Final ESIA Disclosure

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Table 7.1 Phases of Stakeholder Engagement

Phase Objective Key Activities Key Outputs

Screening

Engagement

To gain a preliminary understanding of the scope of the proposed Project, it’s likely impacts and relevant stakeholders.

Inception meeting with Yara Dallol BV and personnel involved in the stakeholder engagement activities;

Site screening field visit; and

Stakeholder identification process.

SEP for the ESIA;

Summary of screening issues raised and stakeholders identified.

Notification and

Scoping

Engagement

To meet key stakeholders and discuss the proposed Project and ESIA;

To generate feedback on the Draft Scoping Report, including the scope, approach and key issues to be investigated further in the ESIA process; and

To consult key stakeholders on the next steps in the ESIA process.

Formal submission of Draft Scoping Report to Authorities;

Distribution of draft Scoping Report and /or Background Information Document (BID) to key stakeholders;

Stakeholder consultation on the proposed Project and associated ESIA through meetings and workshops with identified stakeholders. Details may include: ­ Contextualisation of the proposed Project

with respect to other neighbouring projects and any previous consultation undertaken;

­ Nature, purpose and scale of the proposed Project;

­ Discussion of the ESIA and stakeholder engagement process;

­ Disclosure of scoping findings, including identification of preliminary impacts;

­ Feedback regarding findings; and ­ Dissemination of engagement materials

(BID, posters etc.).

Updated SEP;

Stakeholder database;

Engagement tools and records of their dissemination;

Final Scoping Report with record of stakeholder issues;

Non-technical presentation and posters summarising the draft Scoping Report including list of preliminary identified impacts;

Meeting minutes; and

Updates to project website.

Baseline Data

Gathering

Engagement

To gather data to form a comprehensive understanding of existing baseline conditions of the socio-economic environment; and

To allow stakeholders to raise concerns and expectations regarding the proposed Project.

Further engagement for the purposes of additional baseline data gathering through:

­ Workshops ­ Focus Group Discussions (FGD) ­ Key Informant Interviews (KII)

Updated SEP;

Updated stakeholder database;

Engagement tools;

Updated socio-economic baseline;

Meeting minutes; and

Updates to project website.

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Phase Objective Key Activities Key Outputs

Draft ESIA

Consultation and

Disclosure

Engagement

To discuss the identified impacts and proposed mitigation measures with stakeholders allowing for their input; and

To provide stakeholders with the opportunity to comment on the Draft ESIA report.

Dissemination of the Draft ESIA to Authorities and key stakeholders;

Dissemination of engagement materials (BID, posters etc.) disclosing findings of the draft Impact Assessment Report;

Consultation on the draft ESIA Report. This included: ­ Identification of impacts in the draft ESIA

and proposed mitigation; ­ Identification of stakeholder concerns and

opinions on the impacts identified; ­ Involvement of stakeholders in assessing the

efficacy and suitability of the proposed mitigation measures; and

­ Identification of revisions or additions to the draft ESIA report where necessary.

Draft ESIA Report;

Non-Technical Summary of identified impacts and mitigation measures;

Updated SEP; and

Updates to Project website.

Final ESIA

Disclosure

Engagement

To get sign–off and formally submit the Final ESIA to the authorities and key stakeholders with comments incorporated from the Scoping and draft ESIA engagement and disclosure stages.

Disclosure of the Final ESIA Report with stakeholders.

Final ESIA Report; and

Final SEP.

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7.2.1 Differentiated Approach to Engagement

It is important to note that a significant proportion of stakeholders within the

communities identified within the Project Area may have been previously

engaged either directly by Yara Dallol BV or by other companies operating in

the greater Project Area.

Work to date on neighbouring projects already points to stakeholder fatigue

and despondency amongst key stakeholders in whom expectations have been

raised for benefits and assistance from developers and mining companies. The

risk of baseline survey and engagement teams finding stakeholder fatigue and

or unmet expectations influencing the ability to engage stakeholder in a

comprehensive manner has been considered in the design of the SEP.

In response to this risk a two pronged process for stakeholder engagement has

been designed that is outlined in Figure 7.2, and includes the following:

Courtesy and Confirmatory engagement and disclosure for those that

have been engaged previously with respect to potential impacts of

neighbouring projects (and will be less impacted by this Project).

Detailed Engagement and Disclosure for those newly identified

stakeholders in additional locations, which fall specifically within the Yara

Dallol BV area of influence (the socio-economic area of influence is defined

in Chapter 9). The area of influence can be defined as an area likely to be

disturbed by the Project activities during the pre-construction,

construction and operation phases. The effects can be positive or negative,

short or long term or permanently, direct / and in-direct.

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Figure 7.2 Approach to Stakeholder Engagement

7.2.2 Project Stakeholders

For the purposes of the stakeholder engagement, a stakeholder is defined as

any individual or group which is potentially affected by the proposed Project

or who has an interest in the proposed Project and its potential impacts. A

diverse range of stakeholders were identified and involved in the stakeholder

engagement process. Furthermore, different issues are likely to concern

different stakeholders, and so different types of stakeholder have been

grouped for engagement and consultation based on their connections or

interests in the proposed Project.

Table 7.2 identifies the range of stakeholder groups that are likely to be

interested and / or affected by the proposed Project.

Different issues are likely to concern different stakeholders, and so different

stakeholder groups have been established based on their anticipated interest

in the proposed Project.

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Table 7.2 Project Stakeholders

Stakeholder

Categories

Stakeholder Groups Stakeholder

Government Federal, regional and local government:

political

ANRS Council

Woreda administrators for Dallol and Berahale

Kebele leaders for project affected Kebeles in Dallol and Berahale Woredas

Federal, regional and local government:

administrative and technical

Ministries at federal level (including Ministry leads and technical support e.g. Ministry of Mines and associated offices at the regional and local level)

Bureaus at regional level

Offices at woreda level

Government agencies Ethiopian Wildlife Conservation Authority

Directly Affected

Stakeholders*

Customary authorities (per village) Clan leaders

Religious leaders

Elders

Community associations (per village) Women’s Federation

Youth Groups

Palm Association

Berahale Salt Association

Community members, including men,

women, youth, artisanal salt workers

Bada

Asabuya

Musley

New Alai lai and Mororo

Hamad Ela

Asabolo

Ambule

Morror

Berahale Town Business Mining companies in the northern Danakil

Potential suppliers

Salt related business: ­ Berahale Salt Selling ­ Mekele Salt Buying Associations ­ Subsidiary services including local restaurants, hotels, accommodation etc. in

Berahale, Asabolo, Hamad Ela

Tourism operators working in the Danakil Depression

National Tourism Operator and Travel Agency (NTO)

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Stakeholder

Categories

Stakeholder Groups Stakeholder

Civil Society Federal / national and regional NGOs Forum for the Environment

MELCA

Matrix Development Solutions

Afar Pastoralist Development Association

International NGOs (working or with an

interest in the Danakil Depression)

AMREF

The International Red Cross

Farm Africa

SOS Sahel

Other international NGOs e.g. Norwegian organisations

Academics and research institutes Ethiopian Authority for Research and Conservation of Cultural Heritage

Addis Ababa University

Ethiopian Biodiversity Research Institute

Mekele University

Semera University

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An outline of the stakeholder engagement activities undertaken in each phase

of the ESIA is provided in Sections 7.3 to Error! Reference source not found.,

and a summary of the engagement is provided in Table 7.1.

7.3 SCREENING ENGAGEMENT

Screening phase engagements were undertaken between 11th and 15th

November 2013. The primary objective of the engagements were to identify

social receptors in the project Area of Influence and ‘map’ stakeholders

including directly Project affected people, other stakeholders and social

sensitivities in areas selected for mine related development. The following

activities were undertaken:

Meetings and interviews with key stakeholder groups including local

leaders, men and women; and

General site reconnaissance through driving and walks, transect walks,

taking GPS reading for mapping purposes, observation and capturing

photography with a Yara representative.

Table 7.3 provides a schedule of screening activities that were undertaken.

Table 7.3 Schedule of Screening Activities Undertaken

Day Schedule Data Collection Activities

11 November 2013 Camp induction

Planning of forthcoming

activities

NA

12 November 2013 Site visit and overview

Asabuya village

identification

Recording geo-spatial

information (1) Photographs

Preliminary engagement

13 November 2013 Bada Town identification

and

Musley village

identification

Recording geo-spatial

information

Photographs

Preliminary engagement

14 November 2013 Natural resource transect

walk

Village identification

Interview with Site

Manager

Recording geo-spatial

information

Photographs

Preliminary engagement

Natural resource ranking

15 November 2013 Provisioning ecosystem

services identification

Recording geo-spatial

information

Photographs

More information about the engagement activities undertaken during each of

these phases as well as the outcomes of these visits are described in the SEP

(refer to Annex C in Part II of this ESIA) and its associated appendices.

(1) This included recording information regarding the following social topics – existing settlements, as well as remains of

old settlements, social infrastructure and key resources e.g. water sources.

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7.4 ENGAGEMENT DURING THE SCOPING PHASE

In March 2014, the Scoping Report was made available to stakeholders for a

four week comment period. As part of this disclosure and consultation on the

scoping report, a round of stakeholder engagement was conducted by the

ESIA team. The Scoping engagement involved consultation with stakeholders

at the federal, regional, and local levels. The objectives of this phase were to

disseminate accessible Project information and to engage stakeholders

regarding the ESIA process, the likely key issues and how they can be

involved.

The following engagement materials were generated and disseminated that

summarised the ESIA process, the key issues and how stakeholders could get

involved in the process:

PowerPoint presentations for government level engagement and

engagement in formal settings.

A Background Information Document (BID).

A simplified version of the PowerPoint presentation used as a flipchart

presentation for engagement at the local and regional level.

These materials were written in non-technical/accessible language and

translated into local languages, and provided information on the following:

A background and description of the proposed Project;

The environment in which the proposed Project will be developed;

Information on the Yara Dallol BV;

Information on the ESIA process and timelines;

Typical impacts associated with similar Projects; and

Information on ESIA consultants and their independence.

Due to the high instance of illiteracy amongst potentially impacted groups in

the proposed Project Area, and due to a history of social and political

marginalisation of some minorities in this region, the ESIA team developed a

series of alternative techniques for the dissemination of Project information to

vulnerable or marginalised communities. This included a series of Focus

Group Discussions (FGDs) and one-to-one meetings that rely on the

dissemination of information through the materials mentioned above, as well

as verbal discussion with the involvement of cultural translators.

Consultation with stakeholders was undertaken through a series of face-to-

face meetings and workshops with key stakeholders at the federal, regional

and local levels. Two variants of PowerPoint presentations were given at each

of the meetings depending on the anticipated technical understanding of the

stakeholder group met. For instance, a more technical presentation was given

to government officials; whilst at a local village level a simplified version of

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the presentation was given. Copies of the BID (translated into Amharic) were

distributed at all meetings.

A list of stakeholders that were engaged at each level, and schedule of their

engagement is presented in Table 7.4 below.

Table 7.4 Stakeholder Consultation Meetings during the Scoping Phase

Organisation Date Location

Federal Government

Ministry of Environmental Protection and Forestry 3 March 2014 Addis Ababa

Ministry of Mines 3 March 2014 Addis Ababa

Ministry of Culture & Tourism 3 and 4 March 2014 Addis Ababa

Ministry of Water, Irrigation and Energy 3 March 2014 Addis Ababa

Ministry of Federal Affairs 3 March 2014 Addis Ababa

In addition the Ministry of Agriculture, Ministry of Women, Children and Youth Affairs, Ministry of Urban

Development, Housing and Construction were contacted and provided with a copy of the Draft Scoping Report for

comment.

Regional Government

Bureau of Environmental Protection, Rural Land Use

and Administration

6 and 7 March 2014 Semera

Bureau of Finance & Economic Development 6 and 7 March 2014 Semera

Bureau of Water Resources 6 and 7 March 2014 Semera

Bureau of Culture & Tourism 6 and 7 March 2014 Semera

Bureau of Mines and Energy 6 and 7 March 2014 Semera

Local Government

Berahale Woreda Council and offices 13 March 2014 Berahale

Town

Dallol Woreda Administration 13 March 2014 Adiquwa

Dallol Bureau of Justice and Security 13 March 2014 Adiquwa Dallol Bureau for Agriculture and Pastoralism 13 March 2014 Adiquwa Dallol Bureau of Economic Development 13 March 2014 Adiquwa

Dallol Bureau of Health 13 March 2014 Adiquwa

Community Associations

Berahale Salt Selling & Buying Association 12 March 2014 Berahale

Town

Women’s Palm Association 12 March 2014 Berahale

Town

Tourism Operators & Experts

Medir Tours 4 March 2014 Addis Ababa

Marinata Tours 4 March 2014 Addis Ababa

Ethioder Plc 4 March 2014 Addis Ababa

Off Road Ethiopia 4 March 2014 Addis Ababa

Federal NGOs

Forum for the Environment 4 March 2014 Addis Ababa

Research and Academic Institutions

Authority for Research and Conservation of Cultural

Heritage

4 March 2014 Addis Ababa

Addis Ababa University (departments of Biology,

Archaeology, Geology)

4 March 2014 Addis Ababa

Semera University 6 and 7 March 2014 Semera

Settlements/Communities*

Ambule 10 March 2014 Ambule

Musley 10 March 2014 Musley

Beheiti (Asabuya) 10 March 2014 Asabuya

Bada Ermile 11 March 2014 Central Bada

Bada Admeruq 11 March 2014 Central Bada

Asabolo 10 March 2014 Asabolo

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Organisation Date Location

Hamad Ela 12 March 2014 Hamad Ela

Morror 13 March 2014 Morror

Resettled Alai lai and Mororo 13 March 2014 Resettled Alai

lai and

Mororo

* Community consultations involved engagement with the clan leader, local elders and religious leaders as

well as selected women and youth as identified by the local elders and clan leader.

Upon completion of engagement during the scoping phase, the development

of the Final Scoping Report took into consideration the feedback gained from

stakeholders during Scoping engagement. A summary of key comments and

concerns raised during this phase of engagement is provided in Section 7.8.

7.5 BASELINE DATA GATHERING ENGAGEMENT

Baseline data gathering was conducted during a period of two weeks between

28th April and 7th May 2014. Although the primary purpose of this phase was

to gather primary data for the socio-economic baseline, it also involved

engagement with stakeholders, and provided stakeholders an opportunity to

provide feedback or ask any questions regarding the proposed Project.

Stakeholder engagement during this phase included meetings with key

government stakeholders at the Woreda and Kebele levels, community based

organisations and local community members.

Engagement objectives during baseline data gathering included:

To understand the existing environmental and socio-economic context of

the Project Area; which will serve as a benchmark of pre-project

livelihoods and conditions.

To inform impact predictions (positive and negative) and assessments of

the ability of receptors and stakeholders to benefit from, adapt to and

accept change.

To further identify stakeholders who are potentially sensitive/ vulnerable

to the proposed Project or able to support in the implementation of

information disclosure and mitigation measures.

To ground-truth stakeholder feedback in order to differentiate between

stakeholder perceived and actual impacts.

Communities engaged were selected based on the following characteristics:

Proximity of the community to the Project footprint;

Type of livelihoods activities engaged in;

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Level of vulnerability;

Dependency of palm leaves products as a main source of income; and

Communities residing in the broader Project Area who enjoy communal

user right on the land in-and-around the Project footprint to harvest

natural resources.

Primary data gathering activities were undertaken using Key Informant

Interviews (KII), Focus Group Discussions (FGDs), and one-to-one meetings.

As part of these engagements, a summary of the proposed Project activities

were presented, BIDs were distributed and a social questionnaire was

administered along with other social data gathering methods, such as

Participatory Rural Appraisal (PRA). Flipchart presentations and maps were

used for the different audiences at the local level and supported the data

gathering engagement activities. These were all produced in non-

technical/accessible language and translated into Amharic.

Table 7.5 provides a list of the meetings undertaken during the data gathering

phase.

Table 7.5 Stakeholder Consultation Meetings during the Social Data Gathering Phase

Date Village/ Gov. Leaders Type of Engagement

28 April

2014

Bada Admeruk FGDs: women, elders and men

Bada Admeruk Kebele leaders

KIIs: Health Care Practitioner

Local guide (to show the team areas used to

collect various natural resources)

29 April 2014 Bada Ermile FGDs: women, elders and men

Bada Ermile Kebele leaders (for health, education,

finance, agriculture, and others)

KIIs: Health Care Practitioner

30 April 2014 Abaa/ Kulili

(Elifan Kebele)

FGD: women and men

KII: Elder

01 May 2014 Dallol Woreda FGD: Woreda Leaders (for health, education,

finance, agriculture, and others)

03 May 2014 Asagosso

Baheita Kebele

FGDs: women, elders and men

Asabuyi FGDs: women, elders and men

05 May 2014 Musley FGDs: women

KII: local man, and elder (woman)

06 May Mororo KII: local household

Hamad’Ela KII: local business woman and man

07 May 2014 Zonal Government FGD/KII: Zone 2 Officials for health, education,

finance, agriculture, and others

A summary of key comments and concerns raised during this phase of

engagement is provided in Section 7.8.

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7.6 DRAFT ESIA REPORT CONSULTATION AND DISCLOSURE

Engagement on the contents of the Draft ESIA report was undertaken in

December 2014 over a two week period. This phase of engagement involved

consultation with stakeholders at the federal, regional, and local levels. The

objectives of this round of engagement were to:

Present the key social and environmental impacts identified in the draft ESIA report, and proposed mitigation;

Involve stakeholders in assessing the efficacy and appropriateness of the proposed mitigation measures;

Capture stakeholder concerns and opinions on the identified impacts; and

Identify revisions or additions to the draft ESIA report where necessary.

This phase of engagement seeks to provide stakeholders an insight into the

predicted impacts and mitigation and allow them an opportunity to contribute

their local knowledge to the assessment and mitigation process. This process

also allowed stakeholders the opportunity to discuss their needs, concerns and

aspirations and to incorporate responses into the specialist investigations and

Project design where possible and appropriate.

The following engagement materials were generated and disseminated:

PowerPoint presentations for federal level engagement and engagement in

formal settings.

A Non- Technical Summary of the Draft ESIA, (which was in both English

and Amharic).

These materials were written in non-technical/accessible language and

translated into Amharic, and provided information on the following:

A background and description of the proposed Project;

The potential Project impacts; and

The proposed mitigation measures.

The ESIA team developed a series of specific techniques for the dissemination

of Project information to vulnerable or marginalised communities. This

included a series of Focus Group Discussions (FGDs) and ranking of impacts

approaches that relied on the dissemination of information through

aforementioned materials, as well as verbal discussion with the involvement

of cultural translators.

A list of stakeholders that were engaged at each level, and schedule of their

engagement is presented in Table 7.6 below.

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Table 7.6 Stakeholder Consultation Meetings

Organisation Date Location

Federal Government

Ethiopian Wildlife & Natural History Society (EWNHS) 2 December 2014 Addis Ababa

Authority for Research & Conservation of Cultural Heritage (ARCCH) 2 December 2014 Addis Ababa

Ministry of Mines (MoM) 2 December 2014 Addis Ababa

Addis Ababa University (AAU) School of Earth Sciences 2 December 2014 Addis Ababa

Ministry of Environment & Forestry (MoEF) 2 December 2014 Addis Ababa

Ministry of Water, Irrigation & Energy (MWIE) 2 and 3 December 2014 Addis Ababa Ministry of Foreign Affairs (MoFA) 3 December 2014 Addis Ababa Ethiopian Wildlife Conservation Authority (EWCA) 2 and 3 December 2014 Addis Ababa Ethiopian Biodiversity Institute 3 December 2014 Addis Ababa Pastoral Community Development Project (PCDP) 3 December 2014 Addis Ababa Ethiopian Tourism Organisation (ETO) 3 December 2014 Addis Ababa Ministry of Agriculture (Land administration and Use Directorate) 3 December 2014 Addis Ababa

Regional Government

Bureau of Mines and Energy 4 and 5 December 2014 Semera

University of Semera 4 December 2014 Semera Bureau of Pastoral Agriculture Development 4 and 5 December 2014 Semera Bureau of Water Resources 4 and 5 December 2014 Semera Afar Design And Supervision Works Enterprise 4 and 5 December 2014 Semera Bureau of Women, Children and Youth Affairs 4 and 5 December 2014 Semera Afar Integrated Basin Development and Villagization Coordination Office 4 December 2014 Semera Bureau of Regional Health 4 and 5 December 2014 Semera

Bureau of Afar Labour and Social Affairs 4 and 5 December 2014 Semera Bureau of Administration and Security 4 and 5 December 2014 Semera

Zonal administrator , Zone 2 5 December 2014 Semera Local Government

Dallol Woreda Administration 8 December 2014 Adiquwa Dallol Bureau of Justice and Security 8 December 2014 Adiquwa Dallol Bureau for Agriculture and Pastoralism 8 December 2014 Adiquwa Dallol Bureau of Economic Development 8 December 2014 Adiquwa Dallol Bureau of Health 8 December 2014 Adiquwa Dallol Bureau of Public Communication 8 December 2014 Adiquwa Dallol Bureau of Militia 8 December 2014 Adiquwa Dallol Bureau of Parliament 8 December 2014 Adiquwa

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Organisation Date Location

Dallol Party Office 8 December 2014 Adiquwa Dallol Bureau of Water Resources 8 December 2014 Adiquwa Dallol Bureau of Women, Children and Youth Affairs 8 December 2014 Adiquwa Dallol Bureau of Civil Services 8 December 2014 Adiquwa Dallol Bureau of Trade and Small Enterprise 8 December 2014 Adiquwa Dallol Police Office 8 December 2014 Adiquwa Berahale Woreda Council and Offices 9 December 2014 Berahale Town

Settlements/Communities*

Bada Admeruk 7 December 2014 Bada

Hamad Ela 10 December 2014 Hamad Ela

Beheiti Kebele 10 December 2014 Beheiti

Asabolo and Ambule 11 December 2014 Ambule

Asabuyi 11 December 2014 Asabuyi

Musley 12 December 2014 Musley

Bada Ermile 12 December 2014 Bada

Mororo and Alai lai 12 December 2014 Mororo and Alai lai

* Community consultations involved engagement with the clan leader, local elders, youths and women. The communities were divided into two groups based on gender.

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During meetings stakeholders were notified of the start of the draft ESIA

comment period, which began on the 2nd of December 2014 and ended on the

2nd January 2015. The availability of the Draft ESIA report was advertised in

two newspapers namely “The Ethiopian Herald” and “The Reporter” (both

adverts were in English). The report was also made available through the

project website.

Upon completion of engagement activities, the ESIA Report was revised to

take into consideration the feedback gained from stakeholders. A summary of

key comments and concerns raised during this phase of engagement is

provided in Table 7.7.

7.7 FINAL ESIA REPORT CONSULTATION AND DISCLOSURE

The Final ESIA report was supplemented by additional stakeholder

engagement efforts during February 2015, namely dislocsure and consultation

of the Final ESIA Report. The objective of this phase consultation was to close

out the stakeholder engagement process and generate ‘sign-off’ by affected

community members on their position in response to the proposed Project as

well verifying the engagement process undertaken.

During this phase of engagement the following activities were completed:

Incorporated Feedback and Updated Final ESIA Report – all feedback received from stakeholders was documented, considered and where relevant incorporated within the Final ESIA Report. This included updating of the Stakeholder Engagement Plan (this document) and the ESIA Stakeholder Enagagement Chapter with records of engagement activities including:

­ Meeting minutes; ­ Attendance registers; ­ Engagement tools; and ­ Updated comment and response report.

Presentation of the Final ESIA Report for ‘sign-off’ by the by the local

Authorities (Woreda and Kebele leaders) and communities.

Disclosure of the Final ESIA Report – the final updated ESIA documents

were submitted to the relevant Authorities for approval.

All engagement tools and materials are appended to Appendix F.

Engagement activities during this phase were undertaken through a series of

consultation events with local stakeholders that seeked to:

Describe where stakeholder revisions to the Draft ESIA were made;

Provide a description of the final impacts identified in the ESIA;

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Receive sign-off from local stakeholders on their position in response to

the proposed Project as well verifying the engagement process

undertaken; and

Identify the completion of the ESIA stakeholder engagement process.

The details for this phase of engagement is provided in detail in Appendix F.

7.8 KEY ISSUES RAISED DURING STAKEHOLDER ENGAGEMENT

The key issues identified during stakeholder engagement (namely Screening,

Scoping, baseline data collection and Draft ESIA) are summarised in Table 7.7

and Table 7.8. These issues together with the findings of baseline data

collection have been considered when compiling the Social Impact

Assessment presented in Chapter 11 (Part I of the ESIA).

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Table 7.7 ESIA Related Issued Raised During the Scoping Phase

Issue Category Issue Details on the Issue Stakeholder Raising Issue

Anticipated

Impacts

Water resources Stakeholders’ at all three levels identified significant concerns around the

perceived scarcity of water in the local area, and potential impacts for

abstraction of water for mining related activities, which may result in

decline of water resources available for the local population and animals.

The abstraction of groundwater could result in a decline of water

recharging the pools located on Mount Dallol (which are key tourist

attractions).

The potential decline in groundwater levels caused by abstraction of

water by Yara could result in the decline in important vegetation in the

area, including plants that livestock and camels feed on, as well as doum

palms that are a key source of income for local women, and hold cultural

value for the Afar people.

All stakeholder groups

Tourism The overall development of the area will deter tourists from visiting the

area, in particular if the area becomes industrialised.

Concerns were raised over the proximity of Yara Dallol BV’s license area,

as well as other developments in the area to Mount Dallol.

The increases in traffic that have already been reported in the local area

from mining companies is reported to be causing pollution (dust) and

disturbance to tourists that stay in Hamad Ela.

The potential decline in water resources will have secondary impacts on

surface water bodies located on and around Mount Dallol, which form

key tourist attractions.

The development of infrastructure (mainly the road) by the federal

government for mining companies in the Danakil Depression will lead to

increases in-migration, resulting in disturbance and pollution of

important landmarks and tourist attractions.

Federal government

Regional government

Local government

Tourism operators

Local communities

In-migration The development of infrastructure in the local area, as well as the

presence of mining companies in the area is likely to result in in-

migration. Concerns were raised over the secondary impacts such as

pressure on existing infrastructure, localised inflation and competition

over land and resources.

In-migration and resulting changes in the local health profile

(communicable diseases including sexually transmitted diseases) is a key

concern. A lot of case studies from the extractives sector elsewhere in

Ethiopia were referenced where increases in the communicable disease

Federal government

Regional government

Local government

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Issue Category Issue Details on the Issue Stakeholder Raising Issue

have not been managed adequately.

Traffic Increases in traffic have been noted in the local area, much of which is

attributed to mining companies including Yara Dallol BV. The increase in

traffic is reported to have led to increased pollution and disturbance to

local residents and tourists.

Concerns over the increases in traffic will lead to disturbance to important

areas, such as those used for salt collection and where important

vegetation is found.

Tourism operators

Federal government

Local communities

Ecology The Danakil is identified to be an area that has not been studied in detail;

therefore there are concerns that species (flora and fauna) exist that are

specific to the Danakil and may be threatened by project activities.

The potential decline in water resources due to groundwater abstraction

by Yara Dallol BV may threaten local biodiversity.

Further studies should be conducted with regards to the ecological nature

of the area, taking into account potential seasonal variations in the local

ecology.

Academic and research

institutions

Regional government

Local government

Health Potential impacts on the health and safety of people recruited by Yara

Dallol BV, in particular local people who may not be accustomed to

working for a mining company.

Changes to the community health profile (increases in communicable and

sexually transmitted diseases) due to potential in-migration of people, as

well as the introduction of a workforce by Yara Dallol BV.

The potential decline in water resources due to mining activities may

have consequences on community health, as they access water through

hand dug wells. In addition there maybe secondary impacts to key

resources (salt, palms) that are used to generate income.

Federal government

Regional government

Local government

Local communities

Community associations

Military There is reported to be an unnecessary use of the military in the local area,

as well as recruitment of militia.

Reports of the military being used to threaten stakeholders (in particular

local communities).

Regional government

Local communities

Access and use of land (and natural resources)

Land use and access is still administered through a common property

regime, although government policies contradict this.

People in the local area are mobile, and are accustomed to accessing land

and resources in a seasonal nature. The movement of people and

pastoralist activities need to be considered by Yara Dallol BV, as well as in

the ESIA process.

Pastoralists were identified as a potentially vulnerable group, and

measures need to be developed to ensure that pastoralists are able to

Regional government

Local government

Academic and research institutes

Local communities

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Issue Category Issue Details on the Issue Stakeholder Raising Issue

adapt and benefit to any changes that the proposed Project brings.

Archaeology and cultural heritage

There are numerous locations across the local area that are used for

burials.

In addition there are important cultural landmarks such as Mount Dallol

and Ashe Ale that need to be protected from potential disturbance and

damage.

Local communities

Regional government

Local government

Academic and research institutes

Gender The impacts to women need to be considered in the ESIA process.

Women are a potentially vulnerable group due to their position in Afar

society. In addition they chiefly rely on the collection of palms to generate

an income, thus protection of this resource is key.

Women should look to benefit from the proposed Project through

community development activities and employment opportunities.

Regional government

Local government

Community associations

Process Related Engagement Further engagement should be conducted with stakeholders, in particular

with local stakeholders to ensure that they are aware of the proposed

Project, its stages and activities.

Regional government

Local government

Local communities

Methodologies for specialist studies

Request for detailed methodologies around specialists’ studies and their

results should be presented in the ESIA report, in particular the

hydrological studies.

Federal government

Regional government

Academic and research institutes

Communication

and engagement

Consistency in

communication

Inconsistencies in communication with stakeholders were identified at the

local level in particular. This predominantly revolved around

communication regarding labour and recruitment opportunities.

Regional government

Local government

Local communities

The proposed

Project

There are several misconceptions around the proposed Project including:

Ownership of the Project.

Stage of the Project.

Location of the Project.

Regional government

Local government

Local communities

Existing impacts Labour and

recruitment

Numerous concerns were raised with regards to labour and recruitment

practices (actual or perceived) including:

Inconsistency in the way in which contracts are terminated, including

communication around this.

Preferential recruitment and treatment of non-Afar employees.

Inequalities in the positions and salaries offered to Afari employees.

Regional government

Local government

Local communities

Water Concerns were raised that the presence of mining companies in the area

over the past three years has led to a decline in water resources.

Local communities

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Issue Category Issue Details on the Issue Stakeholder Raising Issue

Traffic Complaints raised that Yara Dallol BV (and other mining companies working

in the area) has led to an increase in traffic in the local area, with resulting

impacts to:

Air pollution (dust emissions).

Damage to local vegetation.

Potential accidents with communities and livestock.

Disturbance to tourists.

Local government

Local communities

Tourism operators

Anticipated

benefits

Employment There is considerable expectation for local stakeholders to benefit from

employment opportunities arising from the proposed Project.

The importance of local communities benefiting from the proposed

Project was highlighted at all levels.

Regional government

Local government

Local communities

Community

development

initiatives

Expectation that in addition to employment opportunities, stakeholders will

benefit from community development initiatives.

It was acknowledged that local stakeholders are not likely to largely benefit

from employment opportunities, in particular skilled positions. Therefore it is

expected that local stakeholders should benefit from proposed community

development initiatives including:

Access to potable water;

Support and improvement to health and educational facilities;

Capacity building and skills training.

Federal government

Regional government

Local government

Local communities

Table 7.8 Issued Raised During the Draft ESIA Phase

Issue Category Issue Further Detail on the Issue Stakeholder Raising Issue

Labour and

employment

Recruitment Numerous questions were raised about employment and

recruitment, including:

The number of jobs that will be created.

The number of jobs that will be reserved for the local

population (Afar people).

Future plans to increase the number of Afar people

employed by the Project.

Inequalities in the salaries offered to Afari employees

compared to non-Afari.

Regional government

Local communities

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Issue Category Issue Further Detail on the Issue Stakeholder Raising Issue

Conditions of employment Comments were made from stakeholders regarding the need:

For allowances for the workforce to become part of a

trade union should they wish.

To ensure the presence of a recruitment and employment

policy.

To ensure that all employees have signed contracts and

that the contracts are explained to the workforce.

Regional government

Workforce health and safety Numerous issues/ comments were raised at a regional level

regarding the conditions of employment of the workforce. The

key health and safety considerations suggested included:

Ensure the presence of a recruitment and employment

policy.

Ensure that the availability of equipment for the

workforce.

Ensure the presence of a workforce compensation plan

for on-the-job injuries.

Ensure the presence of a workforce HIV/AIDs policy.

Provision of workforce accommodation with accepted

standard for the workforce.

Regional government

Skills development Stakeholders wanted to know the following regarding skills

development and training:

If Yara Dallol BV will be providing training;

The type of training that will be provided; and

The potential recipients of training.

Regional government

Local government

Local communities

Community Benefits

(excl. jobs)

Community development

initiatives

Issues of community development were raised with the

majority of stakeholders acknowledging that the local people

are likely not going to benefit from employment

opportunities, in particular skilled positions. Therefore, it is

expected that local population should benefit from proposed

community development initiatives including:

Improved access to potable water;

Support and improvement to health and educational

facilities; and

Capacity building and training.

Federal government

Regional government

Local government

Local communities

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Issue Category Issue Further Detail on the Issue Stakeholder Raising Issue

Water

Water abstraction Stakeholders raised concerns related to:

The potential decline in groundwater levels caused by

abstraction of water by Yara Dallol BV could result in the

decline in important vegetation in the area, including

plants that livestock and camels feed on, as well as doum

palms that are a key source of income for local women,

and hold cultural value for the Afar people.

How the abstraction of water for the project could affect

the sulphur pools on Mount Dallol.

Whether the water abstraction model considered the

impacts of climate change.

Whether the abstraction of water (saline and fresh

water) will reduce the natural production of salt.

Federal government

Regional government

Local government

Local communities

The need for Yara Dallol BV to further engage with the

Ministries and Bureaus responsible for water management

was highlighted.

Federal government

Regional government

Local government

Local communities

Yara Dallol BV was requested to bring the water specialist

team to present their finding to the Ministry responsible for

water management as well as share the data that has been

collected for the purposes of the study.

Federal government

The need to understand if the mining companies in Dallol will

be abstracting water from the same fans was highlighted.

Federal government

Blockage of surface runoff Stakeholders raised concerns related to:

The construction of Yara Dallol BV roads blocking water

from reaching the palms, and salt ponds.

That all three mining companies have to varying degrees

blocked surface runoff from reaching palms; with their

secondary roads to the drilling wells and some palm trees

are dying.

The access roads to the testing wells of all three mining

companies are blocking salty surface water from reaching

the salt area. If nothing is done now, there will be no

more salt to mine.

Local government

Local communities

Cumulative Impacts Concerns over the cumulative impacts of water abstraction by

multiple mining companies have the potential to deplete the

Federal government

Regional government

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Issue Category Issue Further Detail on the Issue Stakeholder Raising Issue

water that communities' rely on. Local communities

Air pollution

Increased generation of dust Although the population of Musley is small at present, after

the rains the population increases as people move to the area

for grazing; as such higher numbers of people may be affected

by changes in air quality as a result of the project.

Local communities

Air quality The proposed processing plant contributed to concerns with

changes in air quality particularly the health implications of

constructing a processing plant and perceptions it could

increase emissions. Stakeholders also stated that when there

are high winds they can smell the sulphur from Mt Dallol all

the way in Hamad Ela.

Regional government

Local government

Local communities

Waste

Waste management Concerns were raised regarding the quantities, handling

and disposal of solid and hazardous waste by the

company, with the stakeholders stating that one of the

companies in the area had dumped some chemical on the

surface. This waste chemical is said to be moving closer to

an area where salt collection is being undertaken.

The communities were not sure which company had

disposed of the chemical in the area.

Other stakeholders raised comments regarding the

absence of local waste disposal and treatment areas.

Federal government

Regional government

Local government

Local communities

Radioactive chemicals Concerns with the potential use of radioactive chemicals in the

plant were raised.

Federal government

Biodiversity

Impact on palms Stakeholders raised the following concerns:

Palms are dependent on both saline and fresh water; as

such the decrease in any of these water types has the

potential to affect the palm trees.

The relocation of any palm tree should be undertaken

with guidance of a local person as they have a better

understanding of the plants than experts from abroad.

Local stakeholders have never seen a successfully

relocated palm tree in the area.

Federal government

Regional government

Local government

Local communities

Impacts on salt Concerns were raised regarding the potential contamination

of salt collection areas by chemicals from the project.

Regional government

Local government

Local communities

Fauna Stakeholders raised the following concerns:

Federal government

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Issue Category Issue Further Detail on the Issue Stakeholder Raising Issue

Ensure that wildlife such as the dessert fox, Egyptian

vulture, wild-ass and killifish are not lost due to the

project and its activities.

The project site is a potential wild-ass habitat and this is

an endangered species particularly sensitive to

interference.

In-migration

Increased burden of diseases Stakeholders expressed concerns related to potential changes

to the community health profile (increases in communicable

and sexually transmitted diseases) due to potential in-

migration of people, as well as the introduction of a workforce

by Yara Dallol BV.

Local communities

Cultural heritage

Disruption of burial and

prayer sites

There are numerous locations across the Project Area and

surrounds that are used for burials and prayers and these

should not be disturbed.

Federal government

Local communities

Visual

Change in sense of place Stakeholders at a local level were divided regarding the visual

impacts of the project, especial the proposed processing plant.

Comments varied including:

Measures should be put in place to ensure minimum

changes in the landscape of the area.

There is no need for Yara Dallol BV to use colours that

blend with the natural surroundings, bright colours and

large structures will be acceptable and will transform the

area.

Local communities

ESIA Process

Specialists All people undertaking the study are experts in their fields

and the communities’ trust that the specialist know best.

Local communities

Content of ESIA Some concerns were raised regarding the content of the draft

ESIA which included:

The ESIA should address cumulative impacts;

The social impact assessment should use qualitative and

quantitative data in its analysis of impacts; and

Issues of occupational health and safety should be

highlighted in the ESIA.

Federal government

Perceptions of Yara

Dallol BV

Perceptions of Yara Dallol BV In numerous meetings stakeholders stated that Yara Dallol BV

is a good company and those they have not heard anything

bad about the company.

Regional government

Local government

Local communities

Noise Increased noise levels Stakeholders raised the following concerns: Local communities

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Issue Category Issue Further Detail on the Issue Stakeholder Raising Issue

Project vehicles should not travel at night as they will

increase the noise levels in the area and people will not be

able to sleep.

Although the population of Musley is small at present,

after the rains the population increases as people move to

the area for grazing; as such higher numbers of people

may be affected by changes in noise levels as a result of

the project.

Stakeholder

Feedback

Communication There have been no responses on the issues raised as part of

the Scoping phase of the project.

Federal government

Stakeholder

Engagement

Language of materials Considerations should be made to translate the project

booklets into Afar as a limited number of people can read

Amharic at community level.

Local communities

Presentation The consultants were thanked for presenting detailed findings

of their study in a clear and concise manner.

Local communities

Participation Stakeholders raised concerns that there is a need for better

government participation in the ESIA meetings as the

implementation of the projects will require collaboration

between various government offices.

Federal government

Project Design

Source of electricity Many stakeholders questioned the use of electricity from the

national grid instead of the solar energy which is in

abundance in the area.

Federal government

Regional government

Climate change Some concerns were raised regarding the extent to which

climate change has been considered in the planning for the

project.

Regional government

Seismic Concerns were raised regarding whether the engineering and

planning have undertaken the necessary precautions

regarding seismic activity.

Federal government

Processing plant A concern was raised regarding no mention of the impact

associated with the processing plant in the project

presentation.

Federal government

Regional government

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The key outcomes of draft ESIA engagement are discussed in the SEP Annex C of Part II of this ESIA, which also provides the responses given to the issues and comments raised.

7.9 NEXT STEPS IN THE STAKEHOLDER ENGAGEMENT PROCESS

Following the submission of the final ESIA report the records of engagement

including the endorsement letter verifying the community’s position on the

proposed Project will be appended to the report. This will be reviewed by the

competent authority who will inform Yara Dallol BV of their Record of

Decision (RoD). Following receipt of the RoD Yara Dallol BV will make this

available to stakeholders as well as provide information on the appeals

process. Following the completion of ESIA engagement process ERM’s

stakeholder engagement team will arrange for a handover to Yara Dallol BV of

key project information including the stakeholder database and issues table.

7.10 FEEDBACK MECHANISM

Each round of engagement undertaken has provided stakeholders with an

opportunity to provide input and feedback on the proposed Project and ESIA

process. A feedback mechanism has been put in place for use throughout the

ESIA process to ensure that potential concerns raised by stakeholders during

engagement are acknowledged and addressed in a timely, structured and

culturally appropriate manner. These have been captured by the ESIA team.

It remains important to offer stakeholders an opportunity to both provide

feedback and receive responses after the completion of the ESIA process. In

light of this, Yara Dallol BV has developed an External Feedback and

Grievance Mechanism.

The ESIA feedback mechanism is discussed in further detail in Section 7.10.1,

Yara Dallol BV’s Grievance Mechanism is outlined in Section 7.10.2.

7.10.1 The ESIA Feedback

An ESIA feedback mechanism was communicated to the stakeholders during

the Scoping Phase and it is being managed by ERM and it’s in country

partners TS Environmental Technology. The feedback mechanism seeks to:

Provide Opportunities to Provide Feedback

Record Feedback – all input received through the engagement process

and other communication channels are recorded via meeting records and

the feedback log.

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Generate Responses – the ESIA team together with Yara Dallol BV review

comments received and generate comments after each phase of

engagement.

Communicate Responses to Stakeholders who have Raised Comments –

all opinions and concerns noted during stakeholder engagements are

recorded and a summary of the feedback and comments is maintained.

The following feedback channels have been available to stakeholders through

the course of the ESIA process:

Electronic and telephone feedback, email and telephone contact details

have been made available to stakeholders for the ESIA team and two Yara

Dallol BV contact persons; and

Engagement activities undertaken directly with stakeholders during the

draft ESIA and disclosure phases.

7.10.2 Summary of Yara Dallol BV’s External Feedback and Grievance Mechanism

Yara Dallol BV have recently developed and implemented an External

Feedback and Grievance Mechanism. The mechanism outlines Yara Dallol

BV’s approach to accepting, assessing, communicating, resolving and

monitoring grievances from those affected by Project activities including

contractors’ activities. This mechanism has been implemented in parallel to

the ESIA and will continue to be used by Yara Dallol BV post the ESIA

process. Furthermore, the mechanism is designed to complement the ESIA

engagement process and grievances related to the ESIA can be submitted to

this mechanism.

The section below provides a brief description of Yara Dallol BV’s External

Feedback and Grievance Mechanism.

The mechanism has been designed to meet the requirements of the IFC in

relation to Performance Standards 1, 5 and 7 and it has the following

objectives:

To provide a simple, fair and transparent process for all external parties to

submit feedback and to raise grievances. This shall result in outcomes that

are fair, effective and lasting.

To provide a simple process for company personnel to redress any issues

and concerns raised by stakeholders in a methodical and time bound

manner.

To mitigate risks and impacts to all external stakeholders due to project

operations, demonstrating company care for the wellbeing of its

stakeholders.

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To build trust and goodwill as an integral component of the stakeholder’s

relation activities, and promote trust and respect with stakeholders,

particularly at a community level.

To enable for the systematic identification of emerging issues and trends,

facilitating corrective and pre-emptive engagement.

The mechanism sets out roles and responsibilities for implementation, from

corporate to site level. The document also describes the process for responding

to and dealing with feedback and grievances. Figure 7.3 illustrates the process

described in detail in the Grievance Mechanism.

The Grievance Mechanism stipulates the need for the following:

Training – those responsible for responding to feedback and grievances

must have detailed knowledge on how the project’s feedback and

complaints mechanism.

Record Keeping – all aspects of the feedback and grievance management

process must be comprehensively documented and accurate records

should be maintained.

Reporting - each Yara Dallol BV offices / business unit (site, Mekele,

Addis Ababa) will compile information relating to engagement activities

as appropriate for the weekly social and environmental reports.

Review - the Grievance Mechanism will be periodically audited and

reviewed to determine its accuracy and relevance with regard to

legislation, education, training and technological changes.

The Feedback and Grievance Mechanism states that the Procedure are linked

to the Stakeholder Engagement Plan as both involve interaction with Yara

Dallol BV’s stakeholders.

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Figure 7.3 Operational Process for Grievance Resolution

Source: Yara Dallol BV Feedback and Grievance Mechanism Procedure – Version 1